Civil and criminal fines stemming from anti-corruption noncompliance can be costly. Firms that paid bribes to foreign officials have been subjected to criminal and civil enforcement actions, resulting in large fines, as well as suspension and debarment from federal procurement contracting. In addition, reputation damage can devastate the bottom line and impair shareholder value.

To avoid these consequences, many firms have implemented detailed compliance programs intended to prevent, deter and detect improper payments by employees and agents. It is critical for management to ensure that a robust anti-corruption compliance program is in place. This issue briefs on how to manage corruption risk and uses the FCPA as a framework for this discussion.